EPA’s assault against nanotechnology seems to be getting serious. The minutes of a recent EPA Scientifi
c Advisory Panel (SAP) review of silver nanomaterials, commonly used due to their anti-microbial affect, seem to indicate EPA intends to slow down or even stop commercial use of this product. The SAP review comes against the backdrop of an ongoing campaign by anti-technology pressure groups to stop the use of silver and other nanomaterials.
However, given the absence of evidence that these materials pose any meaningful human health or environmental risk, EPA's actions are difficult to understand. To begin with, the SAP conceded an absence of data suggesting silver ions from silver nanomaterials behave differently than silver ions from any other source. Yet, it assumed without data the rate of silver ion production, as well as the distribution of silver in tissue, “may differ substantially” between silver nanomaterials and other forms of silver. As one industry group points out, these assumption are not well-founded. Even so, the SAP concluded “most existing models are not appropriate for use with silver nanomaterials and will not accurately predict nanosilver exposure scenarios.” Significantly, the SAP used the absence of scientific data as justification for implementation of an onerous and costly testing regime that may deter FIFRA nanopesticide registrants.
The broader context of EPA's actions may give one pause about the agency's intentions for nanotechnology. Among other things, EPA has recently been very secretive about its nanotechnology agenda. For example, it refused my interview request after I said I intended to ask questions regarding the new scientific basis for its policy shifts. Apparently, EPA is not coordinating with the other federal agencies in the NNI. Also, EPA has removed the minutes of the SAP silver nanomaterials meeting from its website.
EPA's conduct is particularly disturbing in light of the “leaked” suggestion the agency may require any pesticide registrant who is aware that some constituent of a registered pesticide product is nanosized to report under FIFRA Section 6(a)(2), and its “coming determination” that substitution of a nanoscale active or inert ingredient for a conventionally-sized active or inert ingredient in a product currently registered under FIFRA requires an application to amend the registration, seem to indicate EPA is aligning with radical anti-technology groups. At this point, the scientific justification for this alignment is frankly difficult to discern.
